AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• In October 2005, Jaime L. and Ronald T., both fifteen years old, were involved in a stabbing incident that resulted in the death of another young man. They were charged as serious youthful offenders with second-degree murder and conspiracy to commit murder. Both entered no contest pleas to one count of second-degree murder and one count of conspiracy to commit second-degree murder.

Procedural History

• APPEAL FROM THE DISTRICT COURT OF LINCOLN COUNTY, Frank K. Wilson, District Judge: The district court held an amenability hearing and concluded that both Jaime and Ronald were not amenable to treatment as juveniles, imposing adult sanctions on both.

Parties' Submissions

• Plaintiff-Appellee (State): Argued that the amenability determination to treatment as a juvenile should be made by the district court, not a jury, and that the plea agreements entered into by Jaime and Ronald waived their right to contest the constitutionality of the statute and the court's decision on amenability.
• Defendant-Appellant (Jaime L.): Challenged the sufficiency of the evidence underlying the district court’s conclusion that he is not amenable to treatment and asserted that a jury, not the district court, must determine the issue of amenability to treatment as a juvenile.
• Defendant-Appellant (Ronald T.): Made similar arguments to Jaime regarding the amenability determination and also contended that the district court used the wrong standard of evidence to evaluate amenability, failed to request or review a predisposition report from the New Mexico Department of Corrections, and that his sentence was imposed in violation of the plea agreement.

Legal Issues

• Whether the constitutionality of NMSA 1978, Section 32A-2-20 (2005) (amended 2009) violates the Sixth Amendment right to trial by jury by directing the district court to make the amenability determination.
• Whether the district court used the correct standard of evidence in evaluating amenability to treatment as a juvenile.
• Whether the district court erred by not requesting or reviewing a predisposition report from the New Mexico Department of Corrections before sentencing.
• Whether the sentences imposed were in violation of the plea agreements.

Disposition

• The Court of Appeals affirmed the district court's decision, upholding the sentences imposed on Jaime and Ronald.

Reasons

• Per CELIA FOY CASTILLO, Chief Judge (JONATHAN B. SUTIN, Judge, CYNTHIA A. FRY, Judge concurring):
  Constitutionality and Waiver: The court found that the defendants waived their right to contest the constitutionality of Section 32A-2-20 by entering into plea agreements. Furthermore, it referenced the Supreme Court's decision in Rudy B., which upheld the statute's preference for judge-made amenability decisions, affirming the constitutionality of the statute.
  Substantial Evidence/Abuse of Discretion: The court reviewed the district court's determination of non-amenability for treatment under Section 32A-2-20(B), finding substantial evidence supported the decision. It noted the district court's discretion in weighing conflicting expert testimony and the defendants' criminal histories and behaviors.
  Predisposition Report and Sentencing: The court agreed with the State that Ronald failed to preserve the argument regarding the predisposition report for appeal. Regarding Ronald's sentencing argument, the court found the sentence was within the maximum penalties accepted under the plea agreement and that the imposition of probation was a reasonable expectation under the agreement's terms.